Interpretation Response #12-0107 ([North American Automotive Hazardous Materials Action Committee] [Mr. Dave Madsen])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: North American Automotive Hazardous Materials Action Committee
Individual Name: Mr. Dave Madsen
Location State: UT Country: US
View the Interpretation Document
Response text:
August 16, 2012
Mr. Dave Madsen
North American Automotive Hazardous
Materials Action Committee
3350 Airport Road
Ogden, UT 84405
Reference No.: 12-0107
Dear Mr. Madsen:
This is in response to your May 22, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to exceptions for air bags and seat-belt pretensioners. You ask if the exception provided in § 173.166(d)(1) applies to shipments described as Class 9, UN 3268 and those described as Class 1.4G UN 0431 air bags and seat-belt pretensioners.
The answer to your question is no. The exceptions provided in § 173.166(d)(1) are applicable only to shipments of Class 9 UN 3268 air bag modules or seat-belt pretensioners. The exceptions are provided in § 173.166 which is assigned in the hazardous materials table (HMT) to the proper shipping names Air bag inflators or Air bag modules or Seat-belt pretensioners. No link to § 173.166 for air bag modules or seat-belt pretensioners is provided in the exceptions column of the HMT for shipments described as Aricles, Pyrotechnic UN 0431. As you mentioned in your letter, proposals have been made addressing this issue in the HM-254 Notice of Proposed Rule Making.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
173.166
Regulation Sections
| Section | Subject |
|---|---|
| 173.166 | Safety devices |